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Take This Environmental Test

A self-audit for environmental compliance could head off huge penalties and fines for your shop. And if after reading this report you find there are still answers you don't have, there's a great place to get them.

So many facets of our lives are regulated these days-to death, some might say-why should auto repair shops be any different. Complying with the huge number of safety and environmental laws that have been passed in recent years could give any shop owner a headache.

Even the most well-organized, best-run shops often need help. In the area of waste disposal especially, running afoul of the law can not only harm the environment, it can put a major dent in your shop's bottom line, in the form of substantial financial penalties.

Fortunately, there is an organization you can turn to that offers a wealth of information you need to achieve environmental compliance-CCAR (Coordinating Committee for Automotive Repair).

CCAR has developed a website (www.ccar-greenlink.org), under a grant from the U.S. EPA. Its purpose is to give automotive businesses a site they can visit to get the information they need to comply with the law. It's fairly complete and it's easy to access.

For in-depth, state-by-state requirements, the CCAR/GreenLink website lists the ombudsman (by name and phone number) in each state. This assistance provider will be the source of information and requirements that are specific to that state and beyond those of the EPA.

The website also has an interesting feature called the "Virtual Repair Shop." In it, the screen shows a shop environment with various pieces of equipment and waste material containers. You just point and click (for example, to the used oil container) and the screen fills up with relevant text on recovering, storing and disposing of used oil. It can be used in conjunction with our "Environmental Compliance Checklist" (see pages 38 and 39) as a self-audit.

Advantages of a Self-Audit

There are several advantages to doing a self-audit, and incentives, too. The obvious advantage is that you'll find out what you need to do before the EPA-or state enforcement agency-stops by. You'll learn a lot about your responsibilities to the local community and to your employees, as well. And, you might even get a stronger feeling about respecting the environment by protecting the environment.

The incentive is that if you report your findings (violations) and show evidence of corrective action within 21 days, you'll probably escape any fines.

Fines are becoming more common because there has been so much information put out over the past five years or so. Today, you're expected to know certain basics about waste management. Taking a few hours to do the self-audit-and possibly avoiding a $30,000 fine-sounds like it could be a smart decision. Playing dumb won't cut it any more.

Some waste materials are classified as hazardous, others are simply regulated. These materials are used in the shop to perform a service or cleanup function. A shop owner must identify and label each hazardous waste material his shop uses or generates. Material Safety Data Sheets (MSDSs), which shops receive with each chemical shipment, help determine which incoming materials are hazardous. They also help determine which waste materials generated by a shop are potentially hazardous.

It's important to measure the quantity of hazardous waste materials your shop generates. This determines your classification as a hazardous-waste generator.

There are three levels of classification: 1. Conditionally Exempt, Small Quantity Generator; 2. Small Quantity Generator; 3. Large Quantity Generator. Shops that generate less than 220 pounds of hazardous waste in a calendar month (that's about half a 55-gallon drum) and store no more than 2200 pounds on site, are Conditionally Exempt. That means they're subject to a whole lot fewer requirements. So, a wise thing to do is to try to reduce to a minimum the amount of hazardous waste you generate.

Hazardous Waste Classifications

There are four categories of hazardous shop wastes-ignitable wastes, corrosive wastes, reactive wastes and toxic wastes.

Ignitable wastes are those waste materials that have a flash point below 140 F. These include paint thinners, parts-cleaning solvents (both halogenated and nonhalogenated) and gasoline.

Corrosive wastes are liquid wastes that have a pH factor of less than 2.0 (strongly acidic) or greater than 12.5 (strongly caustic). Some materials that meet this definition are battery acid, floor cleaners, paint strippers and aluminum cleaners.

Reactive wastes are wastes that spontaneously combust or explode when mixed with air or water. Cyanides and sulfides fall into this category. These are rarely generated in automotive repair or service, however.

Toxic wastes are wastes that contain chemicals that have been classified as hazardous in certain concentrations as measured by the Toxic Characteristic Leachate Procedure (TCLP). This test cannot be performed in the shop. Some materials in the shop that might fail the test are used coolants (they contain lead or cadmium), bulbs or lamps that contain mercury, sludge from a shop-floor drain that could contain benzene or cadmium and sludge from used-oil tanks.

Once these materials are collected, they must be stored in sealed containers marked with the weight and date of collection. Determine if they must be hauled away and disposed of. Select a certified hauler, and examine his credentials carefully.

Hazardous waste containers should be made of a material that's compatible with the contents; that is, there should not be the possibility of a chemical reaction between the container and its contents. Avoid using underground tanks, as they create their own management problems. Keep lids and bungs closed, except when filling or emptying.

Cradle-to-Grave Responsibility

Record-keeping is a significant responsibility of each shop owner who disposes of hazardous wastes. An up-to-date and orderly manifest file must be maintained. It identifies the shop, the location where hazardous wastes are to be delivered, who will deliver them and a description of each waste material. Then, when the site receives and tests the shipment, documents are returned. All of this paperwork should be secured in a three-ring binder. That way, when an EPA inspector comes calling, you'll be able to face him confidently, assuming you have a good working knowledge of the basics and all your paperwork is in order.

It's a smart shop owner who knows exactly which hazardous wastes are generated and in what quantities. He should also know the credentials of his waste hauler, and that the hauler is taking the materials to an EPA-authorized disposal site. There's a very good reason for this: The shop that creates the waste material has a responsibility for it from cradle to grave, as they say. When the waste hauler takes it away, do not believe your responsibilities are over.

Items of Common Concern

Used oil is one of the most common regulated waste liquids collected by repair shops. It must be stored in leakfree, segregated containers that are clearly labeled "Used Oil."

Used oil may be disposed of by assigning it to an authorized waste hauler for transport to an EPA-authorized disposal site. Used oil may also be disposed of by burning it in space-heater furnaces designed for that purpose. It may also be sold to other shops, under certain limited conditions, who'll use it for the same purpose-space heating.

No other shop liquids should be mixed with used oil that's intended to be used for space heating other than brake fluid and transmission fluid, under EPA guidelines. However, since this is one substance that's subject to many state and local requirements, other authorities must be consulted. The ombudsman in each state is a good starting point.

Another fluid that's subject to varying rules throughout the U.S. is used coolant

(antifreeze). Like most waste materials, it must be stored in segregated and labeled containers.

Many on-site recycling machines are capable of restoring used coolant to standards acceptable by many new-car manufacturers; that is, warranties are not voided if recycled coolant is processed by authorized recycling equipment.

Used coolant that has a lead concentration greater than 5 ppm or is mixed with waste solvents and/or gasoline must count as part of the 220 pounds per month limit classification as a Conditionally Exempt, Small Quantity Generator of hazardous waste.

Used lead-acid batteries must be stored right side up in a sheltered (hopefully roofed) area on a concrete surface. The surface also could be a pan that would contain any leakage, or liquid runoff, to floor or outside drains. A waterproof tarpaulin is also recognized as suitable cover.

Used batteries should ultimately be returned to the manufacturer, or to an authorized recycling facility.

Used solvents are usually the byproducts of the parts-cleaning operation. Whether halogenated or not, solvents must be stored in proper containers, and be appropriately labeled. The safest disposal method is to use a contract hauler (such as Safety-Kleen) who will assure, in writing, that the used solvents are properly disposed of.

More than 275 million tires are replaced each year, and their disposal is a major challenge. (The Firestone situation could cause a spike in the curve for 2000.) Reuse of recycled tires in road resurfacing, flooring and as sea reefs has been liberally funded, but there have been very few market successes. The average repair shop has little recourse other than to contract with an authorized waste hauler for removal of old tires from the premises.

Create a Formal Plan

It's extremely important to have a written plan on how to deal with emergency spills of gasoline and other catastrophic situations. Post the plan in a prominent spot in your work area. Include telephone numbers on whom to call in case of an accidental spill. Your top shop waste-management officer, as well as local authorities, should be on that list.

While there are no formal training requirements tied to the three levels of waste generating classifications, it is expected that there will be at least some conferencing with employees. It's vitally important to keep records of such meetings.

At the very least, the shop owner, manager or designated waste-management coordinator should be familiar with the proper hazardous-waste handling, storage, disposal and emergency procedures.

Take a walk around your shop with the checklist that appears on pages 38 and 39 Have your key people read this article. Then schedule a discussion with
all shop personnel. Remember, protecting the environment is respecting the environment!